Privacy Policy – DeepThink Pte. Ltd.

Effective Date: 01 August 2025

1. Introduction

DeepThink Pte. Ltd. ("DeepThink", "we", "us", "our") is committed to protecting your personal data in accordance with the Personal Data Protection Act 2012 of Singapore (PDPA).

This Privacy Policy applies to all services, applications, platforms, and websites operated by DeepThink Pte. Ltd., regardless of the brand or trade name under which they are offered (collectively, the "Platform").

By creating an account, activating your account, or otherwise using the Platform, you agree to the terms of this Privacy Policy.

2. Types of Data We Collect

a. Students

• Name, age, school details

• Learning behaviour, engagement data, and assessments

• Login credentials, usage logs, preferences

b. Parents/Guardians (if applicable)

• Name, email, contact details

• Relationship to student

• Login credentials, usage logs

c. Teachers / Mentors / Administrators

• Name, email, organisation or school affiliation

• Role or designation

• Login credentials, usage logs

d. Automatically Collected Data

• Device information (type, OS, browser, identifiers)

• IP address, geolocation data (approximate)

• Platform usage behaviour, activity logs, analytics

• Cookies, pixels, and similar tracking technologies

3. Legal Basis and Consent

We rely on the following legal bases:

• Consent: By activating your account and using our Platform, you consent to our collection, use, and disclosure of your personal data for the purposes described in this Policy.

• Deemed Consent: Where reasonably appropriate, we may rely on deemed consent under the PDPA, including deemed consent by conduct.

• Legitimate Interests: For analytics, marketing, research, fraud prevention, and platform improvement.

• Legal Obligation: Where required to comply with applicable laws, regulations, or investigations.

For users under 13 years old, verifiable parental or guardian consent is required before account activation. We treat children's personal data as sensitive and implement enhanced protection measures in accordance with Singapore's PDPA and the PDPC Advisory Guidelines on Children's Personal Data in the Digital Environment.

4. Purpose of Collection and Use of Data

We may collect, use, and disclose personal data to:

• Operate, manage, and personalise your account and experience

• Provide, deliver, and improve our educational services and content

• Conduct analytics, profiling, and research on user behaviour and engagement

• Develop and deliver personalised content, offers, and services

• Provide marketing, promotions, surveys, and communications (including personalised or targeted advertising across our Platform and third-party platforms such as Google, Facebook, TikTok, and others)

• Enable interest-based advertising using cookies, device IDs, and other identifiers

• Share insights with advertisers, partners, and affiliates to support business operations and joint marketing activities

• Detect, investigate, and prevent fraud or misuse of the Platform

• Comply with laws, regulations, and enforcement requests

5. Disclosure of Personal Data

We may share personal data with:

• Service providers, vendors, and IT/cloud hosting providers

• Advertising networks, marketing partners, analytics providers, and social media platforms for targeted marketing and advertising delivery

• Affiliates, business partners, and group companies for service and marketing purposes

• Third-party authentication providers (Google, Apple, Microsoft), if used for login

• School administrators, mentors, or teachers managing student accounts

• Regulators, enforcement agencies, or legal advisers as required by law

We may also disclose or transfer personal data in connection with any merger, acquisition, restructuring, financing, or sale of assets involving DeepThink Pte. Ltd.

6. International Transfers

Where personal data is transferred outside Singapore, we will comply with Section 26 of the PDPA and ensure that the receiving party is bound by comparable safeguards.

7. Data Security

We implement reasonable security measures, including:

• SSL encryption and secure storage

• Access controls and administrative safeguards

• Periodic monitoring and security audits

However, no transmission method or storage system is completely secure. To the maximum extent permitted by law, we disclaim liability for any unauthorised access, use, or disclosure of personal data beyond our reasonable control.

8. Cookies and Tracking Technologies

We use cookies, pixels, and tracking technologies to:

• Understand user interaction and behaviour

• Improve services and personalise content

• Enable interest-based advertising and targeted marketing

By using the Platform, you consent to our use of cookies and tracking technologies. Some features may not function properly if cookies are disabled.

9. User Rights

Under the PDPA, you have the right to:

• Access and correct your personal data

• Withdraw consent (affecting future use only)

• Request deletion of your account and associated data

Requests may be directed to our Data Protection Officer (DPO): [email protected]. We will respond within 5 working days.

10. Minors and Children's Data

Our Platform is designed to be used by students, including children, with appropriate parental or guardian consent.

• Users under the age of 13 (including children as young as 6) require verifiable parental or guardian consent before we collect, use, or disclose their personal data.

• We treat children's personal data as sensitive and implement enhanced security and protection measures.

• We follow data minimisation principles for children, collecting only the personal data necessary to provide our educational services.

• If we learn that personal data has been collected from a child under 13 without verifiable parental or guardian consent, we will delete such data promptly.

• Parents and guardians may review, correct, or request deletion of their child's personal data by contacting our Data Protection Officer at [email protected].

11. Changes to This Policy

We may revise this Privacy Policy from time to time. Updates will be posted with the effective date. Continued use of the Platform after any revision constitutes acceptance of the updated terms.